Ethics, values and compliance

mBank’s Code of Conduct applies to all employees of the banks, including managers and management board members. It establishes the standards applicable in interactions between the bank’s employees and the bank’s business partners. The guidelines relate to allowed and forbidden business practicies, appropriate behaviour at work, fundng fules and social responsibility.

Since two years the Ethics Officers operates at mBank, who:

• co-authors and coordinates ethical standards in the bank
• verifies the bank’s compliance with the ethical standards, including giving opinion to the management board from this perspective

• is responsible for promoting ethical conduct among employees, i.e. via Intranet
• creates guidelines, issues opinions and helps employees solve ethical dilemmas

• is a member of the Anti-Mobbing Committee
• represents the bank in the Ethics Committee of the Polish Banks Association
• Ethics Officer reports directly to the president of the management board and oversees compliance area in the bank.

Ethics officer prepares Lessons Learned, accepted by the management board. They are available to all employees and refer to description on real situations when the banks avoided an ethical mistake or corrected, improving work standards based on the knowledge gained.

Actual or suspected incidents of breaking the law, internal regulations and our ethical standards – can be reported by the employees and the clients anonymously not only to the Ethics Officer, but also lodged anonymously in the mSygnał (whistleblowing) system, which is also available online 24/7 from any computer connected to the internet. Detailed information is available under the address.

In 2019 we checked whether our employees know how to deal with ethical dilemmas, i.e. by asking about popularity of channels to report any doubts. The Ethics Officer launched an initiative to create an ethical training.

We implemented ethics in mSygnał as an additional category where our employees can report unethical conduct the same way other wrongdoing can be reported.

The Chief Ethics Officer has addressed ethics-related topics and dilemmas in many off-site meetings with employees, including call center consultants, ambassadors of the empathy strategy, and members of the Management Board and the Supervisory Board. She also co-organised a manager conference on integrity, compliance and ethics for approximately 700 employees. Our Chief Ethics Officer was in charge of the ethics panel during the European Financial Congress.

The policy provides guidelines for the identification and mitigation of corruption risks, the key principles of the code of ethics, and related responsibilities. No Management Board member, manager, employee or associate may justify corruption or bribery by invoking mBank’s interest.

mBank follows a policy of zero tolerance for all forms of corruption, including accepting, offering, requesting, granting and giving consent for additional benefits, objects or payments in order to:

• unlawfully influence a decision,

• obtain or secure an illegal business advantage,

• gain personal benefits.

mBank’s Management Board and employees are required to avoid conflicts of personal and professional interest. They are prohibited from offering any undue benefits, in particular to central or local government officials, civil servants, and politicians.

mBank prevents corruption in a system of three lines of defence. The first line of defence is comprised of the bank’s organisational units. The second line of defence is the Compliance Department which is responsible for setting and monitoring standards of compliance with anti-corruption laws and regulations. The third line of defence is the Internal Audit Department, which evaluates the adequacy and effectiveness of the bank’s anti-corruption system.

The bank expects its business partners (vendors, contractors, service providers who work with mBank and with its clients on behalf of the bank) to comply with the policy. Anti-corruption provisions are included in each contract between the bank and a business partner.

In 2019, 69% members of the managing bodies and 100% of employees have been informed and received training on anti-corruption.

We identified no corruption incidents in 2019.

The policy defines who, and how, is responsible for fraud prevention. The bank follows a policy of zero tolerance for all fraud and attempted fraud by the bank’s employees, clients, contractors, and third parties. mBank requires fair and lawful behaviour of all its employees, clients, and business partners.

mBank’s fraud risk management cycle covers four stages:

mBank has implemented an electronic whistleblowing system, which ensures anonymity of whistle-blowers. It is accessible on all internet-enabled devices.

Whistleblowing rules and the procedures for reviewing reports are defined in internal regulations as follows:

• the identity of the whistle-blower and the person concerned is strictly confidential: their data must not be disclosed to third parties unless required by law;
• the whistle-blower may set up an anonymous inbox to receive updates on actions taken in reaction to the report and/or to provide additional details;
• every whistleblowing report is reviewed by authorised staff to ensure an objective, fair and impartial investigation;
• mBank employees who report suspected fraud in good faith are protected from any form of repression.

Reports are initially reviewed by staff of the Compliance Department. Filed in the system or otherwise, reports are investigated by authorised officers, as the case may be: employees of the Employee Development and Organisational Culture Department, employees of the Foreign Branches, the Ethics Officer, and employees of the Compliance Department. If a report is confirmed, the case is escalated according to the law and the bank’s internal regulations. The rules for reporting fraud to the Management Board and the Supervisory Board are also clearly defined. They cover regular and ad-hoc reports.

Number of reported and confirmed cases of fraud and actions taken in 2019

Each report was investigated, and necessary measures were taken, including reporting to the authorities, freezing accounts.

To prevent money laundering and financing of terrorism, mBank is required by the programme:

• to identify and verify the identity of our clients,
• to identify and verify the identity of beneficial owners of our clients,
• to identify and verify our clients and their beneficial owners according to the criteria of politically exposed persons (PEP),
• to identify the risk of money laundering and financing of terrorism,
• we refuse to work with clients where we identify risks of money laundering and/or financing of terrorism,
• we monitor clients’ transactions to protect mBank from money laundering and financing of terrorism,
• we regularly train our employees. Training is organised and monitored by the Compliance Department.

In 2019 98% of mBank Group employees received training in scope of Anti-Money Laundering and Counter-terrorism.